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Issues: (i) Whether deduction at 40% of incentive bonus was allowable under section 10(14) of the Income-tax Act, 1961. (ii) Whether additional conveyance allowance was allowable under section 10(14) of the Income-tax Act, 1961.
Issue (i): Whether deduction at 40% of incentive bonus was allowable under section 10(14) of the Income-tax Act, 1961.
Analysis: The question was covered by the earlier decision of the Court, which had answered the same controversy against the assessee and in favour of the Revenue.
Conclusion: Deduction at 40% of incentive bonus was not allowable; the issue was decided in favour of the Revenue and against the assessee.
Issue (ii): Whether additional conveyance allowance was allowable under section 10(14) of the Income-tax Act, 1961.
Analysis: The Income-tax Officer and the Commissioner of Income-tax (Appeals) had allowed Rs. 30,000 as additional conveyance allowance on the basis of the circular relied upon, and that view was upheld as a correct interpretation of section 10(14).
Conclusion: Additional conveyance allowance was restricted to Rs. 30,000 and the assessee's claim beyond that amount was rejected; the issue was decided in favour of the Revenue and against the assessee.
Final Conclusion: Both reference questions were answered against the assessee, and the Revenue succeeded on the substantive tax issues.
Ratio Decidendi: Allowance under section 10(14) depends on the statutory limits and the conditions governing the allowance, and a claim beyond the permissible extent cannot be allowed merely on assertion of expenditure.